GIM 39 – Closeout of Sponsored Programs
Contents
Purpose & Background
Sponsors require a final technical (also may be referred to as a programmatic, performance, narrative, progress, or project report), and financial reports or invoicing at the end of an award.
Final Reporting Requirements
The terms of an award will specify final reporting requirements. These may include:
- final technical report
- final financial report or final invoice
- final invention statement
- equipment inventory/property report
- ClinicalTrials.gov report
- security report
- or other items
This policy establishes roles and responsibilities for complying with the closeout requirements for awards.
University Policy
When accepting an award, the University has an obligation to comply with the sponsor’s closeout requirements. The UW expects PIs to close awards in compliance with the sponsor terms and conditions as well as UW policies and procedures for closing out an award.
If we do not follow final closeout requirements the sponsor may:
- Delay future awards to the University
- Require a different payment method on other current awards made to the University
- Withhold future funding to the Principal Investigator, the Principal Investigator’s Department, and the University
- Suspend other current unrelated awards made to the University from that sponsor
Late Expenses
All expenses must post to an award by the final action date or they are considered late expenses and will not be included in the final financial report or invoice and are subject to nonpayment. Such expenditures become the responsibility of the PI to resolve and may need to be transferred to a non-sponsored worktag. See the Deficit Resolution Policy.
Equipment Inventory
According to Equipment Inventory Office (EIO) guidance, the PI must provide timely information to EIO to fulfill final equipment inventory reports.
Ownership and disposition of equipment must follow terms of the award and sponsor policies.
Final Invention Statement
All sponsor invention statements or patent reports must be completed by the PI and submitted according to the sponsor requirements. If an authorized signature is required, the PI is responsible for obtaining OSP review and sign-off.
UW Consequences for Closeout Non-Compliance
OSP does not review and submit new proposals on behalf of a PI if OSP is made aware that the PI is delinquent submitting final technical report, invention statement / patent reports, ClinicalTrials.gov, or other types of reports.
OSP and GCA reserve the right to place a restriction on the delinquent PI’s other awards or take other administrative actions if the PI has not completed final closeout requirements.
Responsibilities
Chair or Department Head
Institute necessary internal controls to ensure final closeout documentation is supported by the department/unit.
If the PI is unavailable or otherwise unable to complete closeout requirements, the Chair or Department Head:
- Coordinates the preparation of final closeout documentation.
- If necessary, works with OSP for approval from the sponsor to submit late or waive closeout documentation.
Dean’s Office
In coordination with the Chair of the Department and according to Dean’s office policies, ensure closeout requirements are met for awards within the unit/school/college.
Principal Investigator (PI)
- Review award terms and conditions for all closeout requirements
- Complete final closeout reporting requirements
- Review the End of Award Recommendations
- Coordinate with all subrecipients on requirements to submit final invoice, invention statement, and other deliverables to be incorporated into the UW’s closeout documentation
- Review all costs charged to the award for allowability & allocability. See GIM 23 for more information
- Make sure cost share obligations have been met and documented
- Assume responsibility over late posting expenses
- Retain copies of all progress/technical reports, including the final, within local award files.
- Coordinate with EIO regarding disposition of sponsor owned equipment
Office of Sponsored Programs (OSP)
- Provide guidance on non-financial sponsor and/or award closeout requirements
- Access sponsor electronic systems to approve closeout documentation as Institutional Authorized Official, if required
- Coordinate with CoMotion to submit invention statements as the Institutional Authorized Official
- Coordinate with Equipment Inventory Office (EIO) to submit equipment or property disposition forms and reports
- If PIs are severely delinquent in closeout requirements, if necessary, OSP will notify the unit and escalate sponsor closeout reminders to the Chair and/or the Dean’s office
- OSP will take administrative actions if the PI has not completed final closeout requirements
Grant and Contract Accounting (GCA)
- Provide guidance on financial sponsor and/or award closeout requirements
- Provides the Award Portal application which allows campus to monitor the expiration and Final Action Date of awards
- Review and prepare UW Awards for financial closeout
- GCA will notify the unit and take administrative actions if the PI has not completed final closeout requirements
Equipment Inventory Office (EIO)
- Authorize the property closeout report and facilitate submission to the sponsor, in coordination with OSP
- Submit official request for equipment disposition if equipment is titled to sponsor
CoMotion
- Reviews and provides concurrence on positive and negative final invention statements
- Submits positive invention statements in some sponsor systems
- Reports subject invention disclosures on iEdison.gov.
Related Resources
- Award Changes
- Closeout Property Report
- Closeout Reporting
- Closing Your Award
- Deficit Resolution Policy
- Dissemination of Results
- Disposition of Federal Equipment
- End of Award Recommendations
- Final Action Date
- GIM 7: Sponsored Program Subaward Administration
- GIM 8: Subrecipient Monitoring
- How to Report Clinical Trial Results
- Subawards – Final Report and Invoice
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Change Notes
Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu